NSF Issues Draft Implementation Plan for OMB Uniform Guidance

The National Science Foundation has published a draft of the NSF implementation plan for the OMB Uniform Guidance (2 CFR 200) and a request for comments in the May 9 Federal Register: Comment Request: National Science Foundation Proposal/Award Information-NSF Proposal and Award Policies and Procedures Guide.

NSF is asking for comments by July 8 on the draft PAPPG, available on the NSF Policy Office site. NSF is interested in public comment on NSF’s implementation of the OMB Uniform Guidance, as well as the policy changes identified in the PAPPG. Comments regarding the content of the Uniform Guidance should not be submitted.

NSF has highlighted text in yellow that implements the Uniform Guidance. Yellow highlighting appears in the following cases:

• Use of specific references to the Uniform Guidance;
• Direct replication of text from the Uniform Guidance; and
• NSF’s implementation of requirements from the Uniform Guidance that are imposed on agencies.

NSF has formally requested from OMB deviations from the Uniform Guidance in only two areas:

• Limitation to two months salary compensation for faculty. and
• Alternative to the Federal Financial Report.

NSF has highlighted in blue policy changes that are being made independent of NSF’s implementation of the Uniform Guidance.

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